The GloBE Model Rules have introduced the Qualified Domestic Minimum Top-Up Tax (QDMTT) into the ruleset of the international compromise on an effective minimum tax (“Pillar 2”). A QDMTT is defined as a domestic minimum tax that applies to local constituent entities of in-scope MNEs and produces outcomes that are consistent with the GloBE rules….
Johannes Becker and Joachim Englisch* After the international political agreement to introduce an effective country-by-country minimum tax on multinational firm profits, there are still some open questions on the design and implementation of the tax[1]. Among other elements, the OECD/G20 Inclusive Framework Statement of 8 October 2021 envisages a “formulaic substance carve-out” for deemed routine…
Just two weeks ago on 8 October 2021, 136 of 140 member countries of the OECD/G20 Inclusive Framework agreed on a global tax deal that also features the GloBE international effective minimum tax (the so-called Pillar 2 of their work program). The G20 finance ministers backed the deal in their subsequent meeting, too. The agreement…
Nevia Čičin-Šain and Joachim Englisch* The sixth amendment of the Directive on administrative cooperation has just been adopted by Council, on 22 March. Earlier drafts of DAC 7 have received certain attention mostly for the new regime of documentation and reporting obligations imposed upon digital platforms. However, the new Directive also features numerous other important…
I. Introductory remarks In its recently closed public consultation on a possible carbon border adjustment mechanism (CBAM) for selected sectors as a key element of the EU Green Deal, the EU Commission has asked for comments on several policy options for such a mechanism. In the accompanying Inception Impact Assessment, the Commission has furthermore set…
According to an undisclosed policy paper that is currently circulated within the OECD, the German government is promoting an internationally coordinated reform of corporate taxation. Specifically, Germany proposes an effective minimum tax on the profits of multinational companies. Complex, easy to manipulate and unfair – there is widespread discontent with the current system of international…
On 21 March, the European Commission will publish a proposal for a two-fold strategy to reform the taxation of digital companies like Google and Facebook. The most recent draft of the proposal that has been distributed on March 15 suggests that one should lower one’s expectations. Last autumn, a group of EU Finance Ministers propelled…
In mid-November, the Republican majority in the US House of Representatives has passed its version of the Tax Cuts and Jobs Act bill. Last Saturday, the Senate has followed suit and has cast a 51:49 approval vote on the parallel tax reform bill introduced by its Republican members. Admittedly, it is still not entirely clear…
